G.R. No. L-48672 July 31, 1987
Tropical Homes, Inc. vs. National Housing Authority, The Provincial Sheriff, Province of Rizal, and Arturo Cordova

FACTS

Petitioner Tropical Homes, Inc. entered into a contract on April 17, 1972, to sell a subdivision lot to private respondent Arturo Cordova. The contract provided for automatic cancellation upon default in payment of any installment within 90 days from its due date. Due to Cordova’s non-payment of installments for seven months, the petitioner cancelled the contract in July 1973 and forfeited his payments as liquidated damages. Cordova later filed a complaint with the National Housing Authority (NHA), seeking a refund of his total payments amounting to P8,627.86.
The NHA, exercising jurisdiction under Presidential Decree No. 957, issued a resolution on February 21, 1978, ordering Tropical Homes to refund Cordova’s payments with interest. The NHA found that a subsequent contract for a house and lot entered into by the parties was in substitution of the first cancelled contract, entitling Cordova to a refund. Petitioner’s motion for reconsideration was denied. Subsequently, P.D. No. 1344 was enacted, granting the NHA exclusive jurisdiction over such claims and providing that appeals from its decisions lie only to the President of the Philippines. Petitioner appealed to the President pursuant to this decree.

ISSUE

Whether Presidential Decree No. 1344, in relation to P.D. No. 957, which vests the National Housing Authority with exclusive jurisdiction over cases involving the real estate business and limits appeals only to the President, is constitutional.

RULING

The Supreme Court upheld the constitutionality of P.D. No. 1344. The Court ruled that the grant of exclusive original jurisdiction to the NHA over cases involving the sale of subdivision lots is valid. Administrative agencies may be vested with quasi-judicial powers over disputes falling within their special technical expertise, a recognition of the need for efficient resolution of numerous controversies that regular courts may not handle as expediently. This delegation does not violate the constitution.
Regarding the mode of appeal, the Court clarified that the provision stating a decision becomes “final and executory” after appeal to the President does not preclude judicial review. The power of the Supreme Court to exercise judicial review through extraordinary writs like certiorari, prohibition, or mandamus remains intact and cannot be diminished by statute. The failure of the President to act on an appeal does not render an NHA decision automatically final and executory, as access to the courts for constitutional questions is always available. Therefore, the law, interpreted in this light, is not unconstitutional. The petition was dismissed.